A doctor's recommendation wasn't enough to force the staffing giant's hand
Staffing giant ADECCO has no legal duty to assign a nurse case manager in a non-catastrophic workers' compensation claim, a Tennessee appeals panel ruled.
The Workers' Compensation Appeals Board handed down its decision on March 24, 2026, affirming a lower court order that denied an injured temporary worker's request for mandatory nurse case management, attorneys' fees, costs and penalties. The case settles a question that has real implications for HR professionals overseeing workers' compensation programs.
Ronnie Slater, a 58-year-old Chattanooga resident, was placed by ADECCO at a company in Georgia. In January 2020, he was helping move large rolls of material when he felt a pop in his back and pain shooting down his left leg. He reported the injury and was eventually diagnosed with a disc herniation with radiculopathy at L5-S1. Surgery followed in September 2020. His back improved, but he continued to report left leg pain, and his doctor referred him to pain management.
Then came a second workplace incident. In late January 2021, Slater tripped over a pallet while reaching and lifting empty boxes, falling backward onto his back. His spine specialist concluded the fall merely exacerbated his underlying back condition of lumbar spondylolisthesis. Over time, Slater also developed knee complaints, but his doctor did not link them to the workplace incidents or offer a diagnosis for the knee.
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